Compliance Program

In order to be sure that workers are not overexposed to lead, employers must create and implement a compliance program (or safety plan) to keep employees below the permissible exposure limit. These plans must include the following:

• A description of every activity that involves exposure to lead. This description could include the equipment or materials used, the controls that are in place, the size of the crew, the responsibilities of employees, the operating procedures, and maintenance practices.
• The technology and engineering controls that the employer will put in place, and the studies used to determine which engineering controls will be used. Engineering controls include things like ventilation, enclosure of lead sources, or substitution of materials. These will be discussed in more detail later.
• Air monitoring data that documents the source of the lead emissions.
• A written schedule that shows when and how this plan will be put into place. This includes documentation of purchase orders for equipment, and construction contracts.

The compliance program must also include the following:

• A list of work practices that will help reduce exposure. Work practices include activities such as hand washing, end of day procedures, and prohibited activities. These will be discussed in more detail later.
• A list of administrative controls that the employer will put in place. Administrative controls include things such as rotating shifts so that no one is exposed for too long.
• Arrangements between contractors, if multiple contractors are working on the same site, to inform affected employees of potential exposure.
• Any other information that could be relevant to keeping the exposure of employees below the permissible exposure limit.

This compliance program should also account for regular inspection of the job site and materials. It must be made available to any affected employees. The compliance program should be revised and updated every six months to reflect changes in the job, job site, available technology, or other circumstances that could change exposure levels.

To learn more about Construction Lead Exposure visit our Cal/OSHA Construction Lead Exposure Online Training web page.